OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 14, 2006

Paul Tsotsos
Director of Facade Examination and Restoration
Soodan & Associates
100 North LaSalle Street
Chicago, Illinois 60602

Re: Guardrail requirements for two point suspension scaffolds

Dear Mr. Tsotsos:

This is in response to your June 10, 2005, letter to the Occupational Safety and Health Administration (OSHA). We apologize for the long delay in providing this response. Your inquiry concerns the guardrail requirements for suspension scaffolds.

We have paraphrased your inquiry below:

Question (1): Is a guardrail required on the interior or wall side of a two point suspension scaffold while it is being raised or lowered?

Answer:

Fall Protection on scaffolds

OSHA scaffolding standards are at volume 29 of the Code of Federal Regulations (CFR) sections 1926.451 — 1926.454. The scaffolding fall protection requirements are located in 1926.451(g). Section 1926.451(g)(1)(ii) states:

Each employee on a single-point or two-point adjustable suspension scaffold shall be protected by both a personal fall arrest system and guardrail system.

When using a guardrail system, all open sides and ends must be guarded as specified in §1926.451(g)(4)(i), which reads in part:

Guardrail systems shall be installed along all open sides and ends of platforms....[Emphasis added].

Exceptions

The standard specifies several exceptions to the requirement to install guardrails at the front edge of scaffold platforms. Section 1926.451(b)(3) does not require fall protection or guardrails when: (1) the front edge of the platform is 14 inches or less (36 cm) from the face of the work; (2) when outrigger scaffolds are 3 inches (8cm) or less from the front edge;1 and (3) when employees are plastering and lathing 18 inches (46 cm) or less from the front edge. Also, under §1926.451(g)(1)(vi), when performing overhand bricklaying operations, there need not be a guardrail on the side next to the wall being laid.

The standard does not include an exception to the fall protection requirements in §1926.451(g)(1)(ii) that apply when the scaffold is raised and lowered. Therefore, the fall protection requirements apply when raising or lowering a two-point suspension scaffold.

Question (2): Scenario: Employees are working from a two-point suspension scaffold with guardrails on three of the four sides of the scaffold — the side facing the wall has no guardrail. The employees are using personal fall arrest equipment.

On occasion the employees must push off the wall in order to move the scaffold around objects which protrude from the wall surface (for example, a window ledge). At such times this momentarily creates a space greater than 14 inches from the wall. Would that constitute a violation of§1926.451(b)(3)?

Answer:

Section 1926.451(b)(3) states:

Except as provided in paragraphs (b)(3) (i) and (ii) of this section, the front edge of all platforms shall not be more than 14 inches (36 cm) from the face of the work, unless guardrail systems are erected along the front edge and/or personal fall arrest systems are used in accordance with paragraph (g) of this section to protect employees from falling.

Sections 1926.451(b)(3) (i) and (ii) state:

(i) The maximum distance from the face for outrigger scaffolds shall be 3 inches (8 cm);
(ii) The maximum distance from the face for plastering and lathing operations shall be 18 inches (46 cm).

 

 

Under these provisions, the general requirement is that when using guardrails all open sides and ends must be guarded. An exception to this requirement applies where the clearance from the platform is 14 inches or less from the face of the work. Since this clearance exceeds 14 inches in your scenario, and the other exceptions quoted above do not apply, section 1926.451(b)(3) is violated.

Note that, in discussing this provision in the preamble to the final rule, OSHA explained that the Agency considered comments suggesting that the maximum allowable clearance distance be less than 14 inches, as well as comments suggesting that it be 18 inches. In deciding not to set a closer maximum distance, the Agency stated that, "[w]hile OSHA recognizes that the suggested 12-inch spacing could be marginally more protective, the Agency also recognizes that...in many cases an unobstructed working space of at least 14 inches is necessary." In rejecting the suggestions that it be greater than 14 inches, the Agency stated that the 14-inch space "appropriately addresses both the safety concerns and the need to allow necessary room for many of the jobs performed from scaffolds." (Volume 61 of the Federal Register on page 46040) (August 30, 1996).

if you need additional information, please contact us by fax at: U.S. Department of Labor — OSHA, Directorate of Construction, Office of Construction Standards and Guidance 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, NW, Washington, DC 20210, although there will be a delay in our receiving correspondence by mail.

Sincerely,



Noah Connell, Acting Director
Directorate of Construction

 

 

1 The standard defines outrigger scaffold in 1926.450 as "a supported scaffold consisting of a platform resting on outrigger beams (thrustouts) projecting beyond the wall or face of the building or structure, the inboard ends of which are secured inside the building or structure."[ back to text ]